This Privacy Notice was last updated on 15 April 2020.
At ilmspired we are committed to protect and respect your privacy in compliance with EU General Data Protection Regulation (GDPR) 2016/679, dated 27 April 2016. This Privacy Notice explains when and why we collect personal information, how we use it, the conditions under which we may disclose it to others and how we keep it secure. This Privacy Notice applies to the use of our products and to our sales, marketing and customer contract fulfilment activities. It also applies to individuals seeking a job at ilmspired.
2. Who are we?
ilmspired is branded software developed and owned by Cordoba Capital Limited. For the purposes of this Privacy Notice, references to ilmspired also infer the owner of the brand. Cordoba Capital Limited is a private company limited by shares incorporated in the United Kingdom under the Companies Act 2006, under number 10915569, with registered office at 3rd Floor, 207 Regent Street, London W1B 3HH.
Cordoba Capital Limited is the data controller and our Data Protection Officer can be contacted by email at email@example.com or by writing to: Data Protection Officer, Cordoba Capital Limited, 3rd Floor, 207 Regent Street, London W1B 3HH.
4. Why do we collect and use personal data?
- 3. When do we collect personal data about you?
- When you are using our products.
- When you interact with us in person, through correspondence, by phone, by social media, or through our website.
- When we collect personal information from other legitimate sources, such as third-party data aggregators, ilmspired marketing partners, public sources or social networks. We only use this data if you have given your consent to them to share your personal data with others.
- We may collect personal data if it is considered to be of legitimate interest, and if this interest is not overridden by your privacy interests. Before data is collected we make sure an assessment is made, ensuring that there is an established mutual interest between you and ilmspired.
We collect and use personal data to record the users of ilmspired in order to track their learning progress and communicate this progress to the account holder (usually a parent, guardian or teacher); to perform direct sales, direct marketing and customer service. We also collect data about suppliers, partners and persons seeking a job or working in our company.
We may use your information for the following purposes:
5.1 Collecting personal data based on consents
- Send you marketing communications which you have requested. These may include information about our products and services, events, activities, and promotions of our associated partners’ products and services. This communication is subscription based and requires your consent.
- Send you information about the products and services that you have purchased from us.
- Perform direct sales activities in cases where legitimate and mutual interest is established.
- Provide you content and venue details on a webinar or event you signed up for.
- Reply to a ‘Contact me’ or other web form you have completed on the ilmspired website.
- Follow up on incoming requests (customer support, emails, chats, or phone calls).
- Provide you with access and services related to a demo version of ilmspired.
- Provide access to Customer Support or the ilmspired Community website.
- Perform contractual obligations such as order confirmation, licence details, invoice, reminders, and similar. The contract may be with ilmspired directly or with an ilmspired partner.
- Notify you about any disruptions to our services (system messages).
- Contact you to conduct surveys about your opinion on our products and services.
- Process a job application.
- 5. Our legal basis for collecting personal data
The collection of personal data based on consent from the data subject will be done by using “Consent Forms” that will store documentation related to the consent given by the individual. Individual consents will always be stored and documented in our systems.
5.2 Collecting personal data based on contracts
We use personal information for fulfilling our obligations related to contracts and agreements with customers, partners and suppliers.
5.3 Collecting personal data based on legitimate interest
We may use personal data if it is considered to be of legitimate interest, and if the privacy interests of the data subjects do not override this interest. Normally, to establish the legal basis for data collection, an assessment has been made during which a mutual interest between ilmspired and the individual person has been identified. This legal basis is primarily related to our sales and marketing purposes. We will always inform individuals about their privacy rights and the purpose for collecting personal data.
6. What type of personal data is collected?
We collect name, phone number, title and email address, as well as your child’s name, sex and age. We may also collect feedback, comments and questions received from you in service-related communication and activities, such as meetings, phone calls, documents, and emails. From our website we may collect IP-address and actions taken on the site.
If you upload photos or videos, add posts or comments on our Community website, the information can be read by anyone with access to the Community site and used for purposes over which ilmspired or you, have no control. Therefore, ilmspired is not responsible for any information you submit to the Community website.
If you apply for a job at ilmspired or Cordoba Capital Limited, we collect the data you provide during the application process.
ilmspired does not collect or process any special categories of personal data, such as public unique identifiers or sensitive personal data.
7. How long do we keep your personal data?
We store personal data for as long as we find it necessary to fulfil the purpose for which the personal data was collected, while also considering our need to answer your queries or resolve possible problems, to comply with legal requirements under applicable laws, to attend to any legal claims/complaints, and for safeguarding purposes.
This means that we may retain your personal data for a reasonable period of time after your last interaction with us. When the personal data that we have collected is no longer required, we will delete it in a secure manner. We may process data for statistical purposes, but in such cases, data will be anonymized.
8. Your rights to your personal data
You have the following rights with respect to your personal data:
- The right to request a copy of your personal data that ilmspired holds about you.
- The right to request that ilmspired corrects your personal data if inaccurate or out of date.
- If you are a customer or partner and you have registered with ilmspired, you may update your user profile by logging into “My Account” and selecting “Edit Account”.
- The right to request that your personal data is deleted when it is no longer necessary for ilmspired to retain such data.
- The right to withdraw any consent to personal data processing at any time, such as your consent to receive e-marketing communications:
- If you want to withdraw your consent to e-marketing, please make use of the link to manage your subscriptions included in our communication. Please note that you may still receive system messages and administrative communications from ilmspired, such as order confirmations, system messages and notifications about your account activities.
- The right to request that ilmspired provides you with your personal data and, if possible, to pass on this information directly (in a portable format) to another data controller when the processing is based on consent or contract.
- The right to request a restriction on further data processing, in case there is a dispute in relation to the accuracy or processing of your personal data.
- The right to object to the processing of personal data, in case data processing has been based on legitimate interest and/or direct marketing.
Any query about your privacy rights should be sent to firstname.lastname@example.org
9. Use of ilmspired by children
ilmspired is an educational app and website designed for children aged 5 to 11. Whilst the majority of users will be children, we do not market directly to children. We collect data about all users and visitors to the site regardless of age, and we anticipate that most of those users will be children. Such child users and visitors will inevitably visit other parts of the site intended for parents, guardians or teachers, and will be subject to whatever on-site marketing they find, wherever they visit.
If you are under 18, you may use our website or app only with consent from a parent, guardian or authorised representative of a teaching institution.
This information is used to make websites work more efficiently, as well as to provide business and marketing information to the owners of the site, and to gather such personal data as browser type and operating system, referring page, path through site, domain of ISP, and so on for the purposes of understanding how visitors use a website. Cookies and similar technologies help us tailor our website to your personal needs, as well as to detect and prevent security threats and abuse. If used alone, cookies and web beacons do not personally identify you.
11. Do we share your data with anyone?
We do not share, sell, rent, or trade your information with any third parties without your consent, except from what is described below:
11.1 Third Party Service Providers working on our behalf:
We may pass your information on to our distributors, agents, sub-contractors and other associated organizations with the purpose of them providing services to you on our behalf.
11.2 Third Party Product Providers we work in association with:
11.3 If required by law:
We will disclose your personal information if required by law or if we, as a company, reasonably believe that disclosure is necessary to protect our company’s rights and/or to comply with a judicial proceeding, court order or legal process. However, we will do what we can to ensure that your privacy rights continue to be protected.
11.4 Use of sub-contractors (processors and sub-processors)
We may use sub-contractors to process personal data on our behalf. We remain responsible for making sure they commit themselves to adhere to this Privacy Notice and applicable data protection legislation by signing a Data Processing Agreement.
If the sub-contractor processes Personal Data outside the EU/EEA area, such processing must be in accordance with the EU Privacy Shield Framework, EU Standard Contractual Clauses for transfer to third countries, or another specifically stated lawful basis for the transfer of personal data to a third country.
12. Changes to this Privacy Notice
ilmspired reserves the right to amend this Privacy Notice at any time. The applicable version will always be found on our website. We encourage you to check this Privacy Notice from time to time to ensure that you are happy with any changes.
If we make changes that significantly alter our privacy practices, we will notify you by email or post a notice on our website prior to the change taking effect.
13. Your right to complain with a supervisory authority
If you are unhappy with the way in which your personal data has been processed, you may, in the first instance, contact the Data Protection Officer at email@example.com
or by writing to: Data Protection Officer, Cordoba Capital Limited, 3rd Floor, 207 Regent Street, London W1B 3HH.
If you remain dissatisfied, then you have the right to apply directly to your national supervisory authority for a decision. In the United Kingdom, the supervisory authority can be contacted at the Information Commissioner’s Office (ICO), website ico.org.uk